PROJECT ALTERNATIVES 1.0 INTRODUCTION

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1 VI. PROJECT ALTERNATIVES 1.0 INTRODUCTION The California Environmental Quality Act (CEQA) Guidelines (Section (a)) require an EIR to (1) describe a range of reasonable alternatives to the proposed project, or to the location of the proposed project, that would feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any of the significant effects of the project, and (2) evaluate the comparative merits of the alternatives. Section (b) of the State CEQA Guidelines directs that this analysis be limited to those alternatives to the project or its location that are capable of avoiding or substantially lessening any significant project impacts, even if those alternative would impede, to some degree, attainment of project objectives, or would be more costly. The selection and evaluation of alternatives is intended to foster meaningful public participation and informed decision-making. As stated in Section (f) of the State CEQA Guidelines, the selection of the range of alternatives required in an EIR is governed by a rule of reason, which requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. Accordingly, an EIR need not analyze alternatives whose effects cannot be reasonably ascertained, or whose implementation might be considered remote or speculative. Of the range of alternatives that would avoid or substantially lessen any of the significant effects of the project, an EIR need only examine in detail those that the Lead Agency determines could feasibly attain most of the basic project objectives. Section (c) of the State CEQA Guidelines require an EIR to identify any alternatives considered by the lead agency but rejected as infeasible during the scoping process, and briefly explain the reasons underlying that determination. According to Section (f)(1), among the reasons for the elimination of possible alternatives from detailed consideration in the EIR are (1) failure to meet basic project objectives, (2) infeasibility, and (3) inability to avoid significant environmental impacts. The determination of feasibility may take into account such variables as site suitability, economic viability, the availability of infrastructure, General Plan consistency, other plan or regulatory limitations, jurisdictional boundaries, and site availability. Section (d) of the State CEQA Guidelines state that alternatives analysis need not be presented in the same level of detail as the assessment of the proposed project. Rather, the EIR is required sufficient information to allow meaningful evaluation, analysis and comparison with the proposed project. If an alternative would cause one or more significant impacts in addition to those of the proposed project, analysis of those impacts is to be discussed, but in less detail than for the proposed project. City of Los Angeles VI-1 Loyola Marymount University Master Plan Project Draft EIR

2 Section (e)(2) of the State CEQA Guidelines require the evaluation of a No Project Alternative, to permit the evaluation of project impacts against those of not approving the project, and an evaluation of an alternative location for the project, if feasible. An environmentally superior alternative is to be identified from the alternatives evaluated; if the No Project Alternative is the environmentally superior alternative, then another environmental superior alternative must be identified from among the remaining alternatives. 2.0 OBJECTIVES OF THE PROPOSED PROJECT Section II, Project Description, sets forth a list of the Applicant s Project Objectives for the Proposed Project. As indicated therein, through the Proposed Project, LMU seeks to improve its campus facilities to accommodate the evolving needs of LMU s academic, administrative, and student-support programs, enhance the educational experience for students, and improve facilities and programs for students, faculty, and staff, within the existing enrollment limits currently in place for LMU. The Proposed Project is intended to guide future campus improvements over the next 20 years. To implement the Proposed Project, LMU is requesting the establishment of the LMU Specific Plan, which would unify the Burns, Leavey, and Hughes Campuses under one set of land use regulations. The Proposed Project s Key and other Objectives are listed below. Key Objectives Key University Objectives U-1. U-2. Implement LMU s three-fold mission: (1) the encouragement of learning, (2) the education of the whole person, and (3) the service of faith and promotion of justice by creating an updated cohesive campus community and environment with a critical mass of approximately 7,800 fulltime equivalent (FTE) students. 1 Attain certainty regarding future development on campus by gaining entitlements that allow for measured, well-managed, and sustainable growth over the next 20 years (growth that will further the pursuit of LMU s mission and promote LMU s key university, academic, residential, and sustainability objectives) to facilitate the establishment of a long-term financial plan for the development of the campus, including fundraising from philanthropic sources, grants, and long-term capital dedication. 1 FTE is a unit of measurement used to calculate enrollment for academic and master planning purposes, as opposed to student headcount. One undergraduate FTE student is defined as one undergraduate student taking 12 course units, which represents a full course load. Students taking fewer course units are considered to constitute a fraction of an FTE student, whereas students taking more than 12 units constitute more than one FTE student. One graduate FTE student is defined as one graduate student taking 9 course units, which represents a full course load. Graduate students taking fewer course units are considered to constitute a fraction of an FTE student, whereas students taking more than 9 units constitute more than one FTE student. City of Los Angeles VI-2 Loyola Marymount University Master Plan Project Draft EIR

3 U-3. Ensure the maximum number of students have opportunities to experience and contribute to LMU s social living and learning environment, student and faculty interaction, and full participation in campus life through increased and improved housing opportunities on campus, including themed housing. Key Academic Objectives A-1. Replace academic, administrative, athletic, and residential spaces and buildings that are functionally obsolete to create a functionally cohesive environment on campus. A-2 Build sufficient state-of-the-art facilities to house future academic, research, and residential uses on campus, to aid in the recruitment and retention of top students, the recruitment of faculty and their conversion from part-time to full-time status, and the creation of the best possible academic community and student social living and learning environment. Key Residential Objectives R-1. R-2. R-3. R-4. Contribute to alleviation of the regional housing shortage through the creation of new student on-campus housing. Increase the percentage of undergraduate FTE students that can be housed on campus from approximately 60 percent to approximately 75 percent through the provision of additional campus housing options. Enhance campus student life by raising the standard of on-campus housing through increased unit size and improved amenities. Foster community and a communal educational environment on campus among the student body by increasing the number of undergraduate FTE students living on-campus and by replacing outdated student housing units with updated social-living units that allow for more communal living and educational exchange. R-5. Replace aging student residential rooms and apartments with modern residential accommodations on campus, to improve the educational environment on campus and aid in student recruitment. R-6. Address existing community concerns regarding students living off-campus by moving more undergraduate residential students onto campus. Key Sustainability Objectives S-1. S-2. Create a sustainable campus environment by incorporating green building and landscaping practices, reducing the production of greenhouse gas emissions and solid waste, and reducing consumption of water, electricity, natural gas, and energy. Move more undergraduate students into campus housing (increasing the percentage of undergraduate residential students from approximately 60 percent of FTE students to City of Los Angeles VI-3 Loyola Marymount University Master Plan Project Draft EIR

4 approximately 75 percent) to reduce traffic trips and vehicle miles traveled to and from the LMU campus. Planning and Design Objectives PD-1. PD-2. Achieve physical improvements in the spatial structure of the campus, and improve pedestrian connections within the campus, to achieve greater integration of academic, administrative, athletic, and residential divisions. Improve land use compatibility on campus and between the campus and neighboring properties. Pedestrian and Vehicular Circulation Objectives C-1. Minimize LMU-related traffic trips to campus and within campus, through measures that include housing approximately 75 percent of undergraduate FTE students on campus. Athletic and Open Space Objectives AOS-1. Provide sufficient and appropriate open space and athletic facilities to meet demand for instructional, intramural and intercollegiate athletics and informal recreation by students, faculty, and staff, by expanding, increasing access to, and appropriately illuminating LMU s athletic facilities for use during daytime and nighttime hours. 3.0 SELECTION OF ALTERNATIVES 3.1 Significant Project Effects As identified in Section IV, Environmental Impact Analysis, after implementation of required mitigation measures, the Proposed Project would result in the following significant and unavoidable impacts: Air Quality Construction Emissions Localized Significance Thresholds (PM10 and PM2.5) As part of the Proposed Project s Air Quality impact analysis, the Proposed Project s construction emissions were evaluated in relation to the South Coast Air Quality Management District s (SCAQMD) recommended localized significance thresholds (LST), which address project construction emissions of specific pollutants and the associated impacts on sensitive receptors in the immediate vicinity of a project site, rather than as with most other thresholds for air quality impacts compliance with regional air quality standards. The South Coast Air Quality Management District has defined specific threshold criteria (i.e., concentrations) for fugitive dust, PM10 and PM2.5, as well as for other criteria pollutants, and the thresholds represent the maximum emissions that would not cause or contribute to the exceedance of an applicable state or federal ambient air quality standard. Impacts are calculated based on ambient City of Los Angeles VI-4 Loyola Marymount University Master Plan Project Draft EIR

5 concentrations of pollutants for in a project area (the Source Receptor Area as defined by the South Coast Air Quality Management District) and distance between the project site and the nearest sensitive receptor. The localized significance threshold impact analysis prepared for the Proposed Project determined that, assuming the most conservative construction scenarios with overlapping demolition, excavation and grading, and building construction activities in a given portion of campus, construction could generate off-site fugitive dust (PM10 and PM2.5) in excess of the applicable localized significance thresholds, significantly impacting residences and a planned school site adjacent to the campus. That is, construction on Burns Campus could exceed localized significance thresholds for PM10 and PM2.5 at residences east, south, and southwest of Burns Campus; construction on Leavey and Hughes Campuses could exceed the localized significance thresholds for PM10 and PM2.5 at residences south of Leavey Campus; and construction on Leavey and Hughes Campuses could exceed the localized significance threshold for PM10 at the northeast end of the Los Angeles Unified School District s (LAUSD s) planned Playa Vista Elementary School site, west of the LMU campus Cultural Resources: Archaeological Resources Cumulative Impacts Development of the Proposed Project in combination with related projects could contribute to the cumulative loss of archaeological resources within the Proposed Project area. All potential sites are required to be evaluated prior to construction activities. Depending on the outcome of these evaluations, there could be possible effects on archaeological resources. Regulations provide a vehicle for preservation of discovered archaeological resources that would otherwise remain unknown. To the extent individual related projects would be required to comply with applicable laws, the potential disturbance, damage or degradation of unique archaeological resources could be mitigated. Although each project must develop adequate mitigation measures to substantially lessen or avoid impacts on an individual basis, the combined incidental loss of archaeological resources in the Project area may constitute a significant cumulative impact Noise Construction Noise Proposed Project-related construction lasting more than 10 days in a 3-month period and exceeding existing ambient noise levels by 5dB(A) or more at the off-campus residences closest to the campus could result in temporary, but significant and unavoidable, Noise impacts at sensitive residential receptors City of Los Angeles VI-5 Loyola Marymount University Master Plan Project Draft EIR

6 adjacent to the campus. These include residences along McConnell Avenue, Fordham Road, Altavan Avenue, W. 78 th Street, W. 80 th Street, and the northern ends of Nardian Way, Altavan Avenue, and Belton Drive Solid Waste Operational Waste Generation As a result of Proposed Project operations, the campus would dispose of approximately 692 additional tons of solid waste per year to landfills, compared to existing conditions. This increase represents less than 0.1 percent of the 2006 disposal rate of approximately 2.1 million tons to the Sunshine Canyon Landfill, the primary landfill serving the campus. According to the 2006 Annual Report for the Countywide Summary Plan and Siting Element of the Los Angeles Countywide Integrated Waste Management Plan (2006 Annual Report), Los Angeles County solid waste disposal demand cannot be accommodated beyond the year 2015 based on the continuation of business as usual practices. This estimate does not account for a number of approved and proposed landfill expansions that would significantly expand landfill capacity, which could be made available to the City of Los Angeles, and the Proposed Project, in the future. However, the 2006 Annual Report does not project landfill capacity beyond For these reasons, it is conservatively assumed that the Proposed Project would result in a potentially significant impact with respect to solid waste at buildout in Cumulative Impacts Solid waste generated as a result of operation of the Proposed Project plus related projects could exceed the capacity of landfills serving Los Angeles County during the 20-year timeframe of Proposed Project buildout. While the Proposed Project is anticipated to account for less than 5 percent of this volume of solid waste, and significant expansions of County landfills as well as development of out-of-county landfills are proposed, it is not yet certain when these expanded or new landfills will become operational. Moreover, the County of Los Angeles Department of Public Works 2006 Annual Report does not project landfill capacity beyond 2021, and therefore future capacity beyond that date cannot presently be confirmed. City of Los Angeles VI-6 Loyola Marymount University Master Plan Project Draft EIR

7 3.2 Alternatives Selected for Analysis Five alternative scenarios have been selected for detailed evaluation and comparison to impacts associated with the Proposed Project. Under State CEQA Guidelines Section (e)(3), the No Project Alternative for a project revising an existing land use or regulatory plan, policy or operation, like the Proposed Project, is the continuation of the existing plan, policy, or operation into the future. The first No Project alternative (Buildout Under Existing Approvals) evaluates impacts that would occur on the Proposed Project site under existing approvals or entitlements. The second No Project Alternative (No Buildout, Maintain Campus As Is) assumes no further development would take place on campus, other than general maintenance and upkeep of existing facilities. In total, five alternatives are evaluated in detail. Each is briefly described below: Alternative 1 No Project Alternative: Buildout Under Existing Approvals. This alternative evaluates operation of the LMU campus under existing City of Los Angeles entitlements and approvals. No additional construction is permitted under LMU s current entitlements. Therefore, under this alternative, the Proposed Project would not be implemented and no additional development on the campus would be undertaken, other than minor improvements required for the general maintenance and upkeep of facilities which do not require further discretionary approvals. However, as permitted under current entitlements, enrollment could increase to the approved cap of 7,800 FTE students and an unlimited increase of faculty and staff would be permitted. (If the increase in faculty and staff is roughly proportional to the increase in students, this increase would be approximately 202 FTE faculty and staff.) 2 Currently (as of Fall 2008), there are 6,868 FTE students enrolled on campus and approximately 1,500 FTE faculty and staff working on campus. This alternative was selected for its potential to avoid or reduce all potentially significant and unavoidable impacts associated with the Proposed Project. Alternative 2 No Project Alternative: No Buildout, Maintain Campus As Is. This alternative evaluates operation of the LMU campus assuming the continuation of existing conditions. Under this alternative, the Proposed Project would not be implemented and no additional development on the campus would be undertaken, other than minor improvements required for the general maintenance and upkeep of facilities which do not require further discretionary approvals. Additionally, there would be no increase in enrollment on campus or increase in FTE faculty and staff levels. Thus, this alternative assumes a static population of 6,868 FTE students and approximately 1,500 FTE faculty and staff. This alternative was selected for its potential to avoid 2 As of Fall 2008, there were 6,868 FTE students and 1,484 FTE faculty and staff. Therefore, there are approximately 216 FTE faculty and staff for 1,000 students, and the resulting increase of 932 FTE students would proportionately represent an increase of 202 FTE faculty and staff. (1,484 FTE faculty and staff / (6,868 / 1,000) FTE students = 216 FTE faculty and staff; 7,800 FTE students / 6,868 FTE students = = increase factor; * 1,484 FTE faculty and staff = FTE faculty and staff) City of Los Angeles VI-7 Loyola Marymount University Master Plan Project Draft EIR

8 or reduce all potentially significant and unavoidable impacts associated with the Proposed Project. Alternative 3 No New or Replacement Residential Uses. This alternative proposes the systematic replacement of academic, administrative, and indoor athletic facilities on campus that are functionally obsolete or substandard, as proposed in the Proposed Project. Similar to the Proposed Project, Alternative 3 would also reconfigure inadequate outdoor athletic facilities and open space areas, roadways, parking facilities, and pedestrian circulation, and would implement infrastructure upgrades as needed. This alternative would permit student enrollment to increase to the previously approved cap of 7,800 FTE students and permit the number of FTE faculty and staff to increase to 1,800, equivalent to the caps proposed under the Proposed Project. However, no new or replacement on-campus housing, nor any off-campus housing, for undergraduate students would be developed. This alternative was selected for its potential to avoid or reduce potentially significant and unavoidable Air Quality, Archaeological, Noise, and Solid Waste impacts associated with the Proposed Project. Alternative 4 Build New Residential Uses Off-Campus. This alternative would involve the implementation of a project similar to the Proposed Project, including the systematic replacement of academic/administrative, athletic, and residential facilities on campus that are functionally obsolete or substandard. Similar to the Proposed Project, Alternative 4 would also reconfigure inadequate campus athletic facilities and open space areas, roadways, parking facilities, and pedestrian circulation accommodations, and would implement infrastructure upgrades as needed. This alternative would permit student enrollment to increase to the previously approved cap of 7,800 FTE students and permit the number of FTE faculty and staff to increase to 1,800, equivalent to the caps proposed under the Proposed Project. However, under this alternative, additional housing beyond what is being replaced on campus would be developed off campus. The additional student housing would require 22 acres within one location. However, a search of properties within 10 miles of the campus did not identify a viable site. As no single property or parcel 22 acres in size is available, student housing would need to be disaggregated within three parcels. This alternative was selected for its potential to avoid or reduce potentially significant and unavoidable cumulative Archaeological and construction Noise impacts associated with the Proposed Project. Alternative 5 Replacement of Existing Residential Uses and 25 Percent Reduction in New and Replacement Non-Residential Square Footage. This alternative would involve the implementation of a project similar to the Proposed Project, including the systematic replacement of academic/administrative, athletic, and residential facilities on campus that are functionally obsolete or substandard. Similar to the Proposed Project, this alternative would also reconfigure inadequate campus outdoor athletic facilities and open space areas, roadways, parking facilities, and pedestrian circulation accommodations, and would implement infrastructure upgrades as needed. However, under this alternative, no additional on-campus housing for undergraduate students would be developed beyond the square footage replacing existing residential uses. Additionally, the square footage of new and replacement academic/administrative and indoor athletic facilities would be reduced by 25 percent compared with the Proposed Project. This alternative was selected for its potential to avoid or reduce potentially significant and unavoidable Air Quality, Archaeological, Noise, and Solid Waste impacts associated with the Proposed Project. City of Los Angeles VI-8 Loyola Marymount University Master Plan Project Draft EIR

9 3.3 Alternatives Considered but Rejected as Infeasible State CEQA Guidelines Section (c) states: The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency s determination. As stated previously, the State CEQA Guidelines stipulate that alternatives addressed in an EIR should be feasible, and not remote or speculative. Several scenarios were considered but dismissed from detailed analysis in the EIR because they did not avoid or reduce significant Project Impacts, meet Key and other Proposed Project Objectives, or were infeasible. These are discussed below Proposed Project Implementation on an Alternative Site This alternative assumes the Proposed Project would be implemented on an alternative site on the Westside of Los Angeles, within reasonable proximity to the Westchester campus. LMU would still demolish functionally obsolete facilities on its existing Westchester campus, but all new construction, including residential and non-residential facilities plus outdoor athletic facilities, would be located on the alternative site. Accordingly, LMU would occupy two campuses: existing, older buildings that would be retained on the present Westchester campus, and newly constructed buildings and outdoor athletic facilities on a second campus in an undetermined location. Proposed Project implementation on an alternative site would avoid significant Air Quality impacts on the residential and planned school uses near the campus and significant Noise impacts on the residential uses near the campus. However, development of an alternative site has the potential to merely transfer Air Quality and Noise impacts, as well as other significant, but mitigable, Proposed Project impacts such as Shade and Shadow, Light and Glare, Biological Resources, Energy, and Transportation, to a new location, since substantial construction would be required at an alternative site. Moreover, given the density of development in the vicinity of campus, the potential, and even likelihood, exists for more sensitive receptors to be affected by construction related emissions and noise at an off-site location than under the Proposed Project. Proposed Project relocation would not, therefore, necessarily avoid or reduce significant Air Quality and Noise impacts associated with the Proposed Project. Proposed Project implementation on an alternative site would avoid significant impacts on Archaeological Resources located on LMU s Westchester campus. Since no sizeable greenfield (i.e., undeveloped) sites are available for development in the vicinity of campus and most alternative locations would likely not have undisturbed archaeological sites, it is unlikely that Proposed Project implementation on an alternative site would result in greater impacts on Archaeological Resources than the Proposed Project, and therefore this alternative s impacts on such resources would likely be similar to City of Los Angeles VI-9 Loyola Marymount University Master Plan Project Draft EIR

10 or less than those of the Proposed Project. However, this alternative would still entail substantial new construction on an alternative site within reasonable proximity of the Westchester campus, and the potential presence of archaeological resources on alternative sites cannot be entirely ruled out. Accordingly, Proposed Project implementation on an alternative site could conceivably result in the loss of resources or their settings on that site. Impacts on Archaeological Resources would therefore still be potentially significant, and a considerable contribution to cumulatively significant impacts would not necessarily be avoided or reduced. Demolition of existing, functionally obsolete facilities on LMU s Westchester campus could still take place under this alternative, and, in addition, construction on an alternative site could necessitate demolition of existing buildings on that site as part of redevelopment. The same amount of new construction would be needed and take place at an alternative site as under the Proposed Project. Construction-related waste generation could, therefore, conceivably be greater under this alternative than under the Proposed Project, although construction Solid Waste impacts would likely remain less than significant. With respect to operations, this alternative would construct the same amount of residential and nonresidential square footage as the Proposed Project, merely at a different location within Los Angeles County, and would necessitate waste disposal during subsequent operation at the same landfills. Therefore, the Proposed Project s operational Solid Waste impacts would merely be transferred to the alternative site, but otherwise would be similar to the Proposed Project. This alternative would have a cumulatively considerable contribution to cumulatively significant Solid Waste impacts. Since this alternative would split campus operations between two sites, necessitating commuting between the sites, it would prevent attainment of Key University Objective U-3, ensuring the maximum number of students have opportunities to experience and contribute to LMU s social living and learning environment, student and faculty interaction, and full participation in campus life through increased and improved on-campus housing opportunities. This alternative would allow incomplete attainment of the remaining two Key University Objectives: implementing LMU s three-fold mission by creating an updated, cohesive campus community and environment (Objective U-1), and attaining certainty regarding future development on campus that allows for future growth, the pursuit of LMU s mission, and promotion of its other Key University, Academic, Residential, and Sustainability Objectives (Objective U-2). Because this alternative would locate all new construction on an alternative site rather than integrating them into LMU s existing Westchester campus, it would allow incomplete attainment of the two Key Academic Objectives: replacing functionally obsolete academic, administrative, athletic, and residential spaces and buildings to create a functionally cohesive environment on campus (Objective A-1), and City of Los Angeles VI-10 Loyola Marymount University Master Plan Project Draft EIR

11 building state-of-the-art facilities to house future academic, research, and residential facilities on campus, to aid in the recruitment and retention of students and faculty, and the creation of the best possible academic community and social living and learning environment (Objective A-2). Because this alternative would not allow the construction of new residential and nonresidential facilities on LMU s campus, it would attain only one of the Proposed Project s six Key Residential Objectives: contributing to the alleviation of the regional housing shortage (Objective R-1). This alternative would prevent attainment of the remaining five Key Residential Objectives, including increasing the percentage of FTE students housed on campus from approximately 60 percent to approximately 75 percent (Objective R-2); enhancing campus student life by raising the standard of on-campus housing (Objective R-3); fostering community and a communal educational environment by increasing the number of FTE undergraduate students living on-campus and by replacing outdated student housing units with updated social-living units (Objective R-4); replacing aging student residential rooms and apartments with modern residential accommodations, to improve the educational environment on campus (Objective R-5); and addressing community concerns regarding students living off-campus by moving more undergraduate residential students onto campus (Objective R-6). By requiring all new construction to be located on an alternative site and not permitting the replacement of aging facilities on LMU s main campus, this alternative would prevent attainment of Key Sustainability Objective S-2, moving more undergraduate students into on-campus housing to reduce traffic trips and vehicle miles traveled to and from the LMU campus (even a shuttle service between the two campuses would likely not be sufficient to achieve this objective), and would allow incomplete attainment of Key Sustainability Objective S-1, creating a sustainable campus environment incorporating green building and landscape practices, reducing the production of greenhouse gas emissions and reducing the consumption of water, electricity, natural gas, and energy. Finally, this alternative would prevent attainment of most other stated Project Objectives, including Planning and Design Objectives PD-1 and -2 and Pedestrian and Vehicular Circulation Objective C-1. This alternative would allow incomplete attainment of Athletic and Open Space Objective AOS-1, since Proposed Project implementation on an alternative site would not preclude the construction of new athletic facilities at that location, although it would preclude improvements to existing recreational facilities on LMU s current campus, such as the nighttime lighting of athletic fields. With respect to feasibility, LMU already owns the existing Westchester campus and it is already developed for university uses. No comparable property suitable for the development of the new and replacement academic, administrative, residential, and athletic uses planned under the Proposed Project exists in the campus vicinity. City of Los Angeles VI-11 Loyola Marymount University Master Plan Project Draft EIR

12 This alternative would result in significant and unavoidable Solid Waste impacts, similar to the Proposed Project, and would not necessarily avoid or reduce the Proposed Project s significant and unavoidable construction Air Quality, Archaeological Resource, and construction Noise impacts. Moreover, this alternative prevents attainment of most Key Objectives and all other Project Objectives, and allows incomplete attainment of AOS-1. For this reason, Proposed Project implementation on an alternative site was rejected as a feasible alternative for detailed evaluation and comparison to the Proposed Project Alternative to Eliminate Significant Construction-Related Air Quality and Noise Impacts The localized significance threshold (LST) impact analysis prepared for the Proposed Project determined that, assuming the most conservative construction scenarios with overlapping demolition, excavation and grading, and building construction activities in a given portion of campus, construction could generate off-site fugitive dust (PM10 and PM2.5) in excess of the applicable localized significance thresholds. Specifically, construction on Burns Campus could exceed localized significance thresholds for PM10 and PM2.5 at residences east, south, and southwest of Burns Campus; construction on Leavey and Hughes Campuses could exceed the localized significance thresholds for PM10 and PM2.5 at residences south of Leavey Campus; and construction on Leavey and Hughes Campuses could exceed the localized significance threshold for PM10 at the northeast end of LAUSD s planned Playa Vista Elementary School site, west of the LMU campus. Proposed Project construction activities could also result in potentially significant and unavoidable Noise impacts on off-campus residences in several locations adjacent to the campus perimeter. Construction that lasts more than 10 days within any given three-month period and exceeds existing ambient exterior noise levels at sensitive receptors by 5 db(a) or more is considered significant. Existing background noise levels were determined to range from 56 db(a) at the southwest corner of Burns Campus to 60.3 db(a) adjacent to the waste management and recycling area on the east edge of Burns Campus. Proposed Project construction was modeled to potentially generate noise levels between 68 db(a) and 95 db(a) as measured 50 feet from noise sources (conservatively assuming simultaneous operation of multiple pieces of equipment at grade, a scenario that is likely to be infrequent in actuality). Conservatively assuming no intervening buildings or structures on campus that attenuate noise, construction in some areas of campus could potentially increase existing ambient exterior noise levels at off-site residences near the campus perimeter by 5 db(a) or more. Specifically, construction could result in short-term, but potentially significant and unavoidable, impacts at the following locations: east of Burns Campus along McConnell Avenue; south of Burns Campus along W. 80 th Street; southwest of Burns Campus along Fordham Road; and south of Leavey Campus along W. 78 th Street, and the portions City of Los Angeles VI-12 Loyola Marymount University Master Plan Project Draft EIR

13 of Belton Drive, Nardian Way, and Altavan Avenue north of W. 80 th Street. Only the northwest corner of the Burns Campus is sufficiently distant from residential uses to entirely preclude potentially significant Noise impacts on such uses. Therefore, in order to avoid the Proposed Project s significant and unavoidable construction-related Air Quality and Noise impacts, demolition and construction could not take place anywhere on LMU s campus where such activities would generate emissions that exceed localized significance thresholds for criteria pollutants at off-site residences or the planned LAUSD school site, or where such activities could subject adjacent residences to an increase in ambient exterior noise levels of 5 db(a) or more for more than 10 days in a three-month period. Accordingly, demolition or construction could take place only in the northwestern corner of Burns Campus, roughly defined as the area bounded by Alumni Mall on the east and LMU Drive on the south. No demolition or construction could take place elsewhere on LMU s campus, including the eastern, central and southern portions of the Burns Campus and Leavey Campuses, or anywhere on the Hughes Campus. This would greatly reduce, if not eliminate altogether, any opportunities for replacement and net new square footage that could be developed campuswide, since new construction would be limited to a small portion of the overall campus and the Proposed Project building height limits would still be applicable, limiting the development density that could be constructed in this reduced area. Student residential facilities on the east and west sides of the Burns Campus could not be replaced and new student housing could not be built; indoor and outdoor athletic facilities in the southern half of the Burns Campus could not be improved or replaced; and administrative facilities on the Burns Campus could not be replaced. Moreover, this alternative is likely to increase some impacts compared to the Proposed Project, including Archaeological Resources (known archaeological sites in the northwest corner of Burns Campus); Paleontological Resources (fossil-bearing rock units in the northwest corner of Burns Campus; and Historic Resources (significant, unavoidable impacts on historically significant buildings in the northwest corner of Burns Campus dating to the campus s establishment). Several beneficial project impacts would not be realized under this reduced construction footprint alternative, including those related to Aesthetics (campus perimeter improvements, increased campus perimeter building setbacks); Air Quality (relocation of waste management/recycling area from the eastern edge of Burns Campus); Climate Change (improved energy efficiency associated with replacement buildings and reduced trip generation for student residents); Surface Water Hydrology and Water Quality (improved stormwater runoff quality); operational Noise (relocation of waste management/recycling area from the eastern edge of Burns Campus, reduction in roadway noise because of reduced trip generation for student residents); Traffic and Parking (improved circulation, increased City of Los Angeles VI-13 Loyola Marymount University Master Plan Project Draft EIR

14 campus parking supply); and Energy (improved energy efficiency and water conservation associated with replacement buildings and the use of reclaimed water for future irrigation). Because this alternative would severely limit LMU s ability to improve existing facilities or construct new facilities, it would prevent attainment of all three Key University Objectives, including implementing LMU s threefold mission by creating an updated, cohesive campus community and environment with a critical mass of approximately 7,800 FTE students (Objective U-1); attaining certainty regarding future development on campus that allows for future growth, the pursuit of LMU s mission, and promotion of its other Key University, Academic, Residential, and Sustainability Objectives (Objective U-2); and ensuring the maximum number of students have opportunities to experience and contribute to LMU s social living and learning environment, student and faculty interaction, and full participation in campus life through increased and improved on-campus housing opportunities (Objective U-3). Because of the reduced construction footprint, this alternative would prevent attainment of both Key Academic Objectives: replacing functionally obsolete academic, administrative, athletic, and residential spaces and buildings to create a functionally cohesive environment on campus (Objective A-1), and building state-of-the-art facilities to house future academic, research, and residential facilities on campus, to aid in the recruitment and retention of students and faculty, and the creation of the best possible academic community and social living and learning environment (Objective A-2). This alternative also would prevent attainment of all six Key Residential Objectives, since very little existing student housing could be replaced or new student housing constructed under this alternative. By not permitting the replacement of aging facilities on the Westchester campus with new facilities built to current standards, this alternative would prevent attainment of both Key Sustainability Objectives: creating a sustainable campus environment incorporating green building and landscape practices, reducing the production of greenhouse gas emissions and reducing the consumption of water, electricity, natural gas, and energy (Objective S-1), and moving more undergraduate students into on-campus housing to reduce traffic trips and vehicle miles traveled to and from the LMU campus (Objective S-2). Finally, the reduced construction footprint alternative would prevent attainment of all other stated Project Objectives, including Planning and Design Objectives PD-1 and -2; Pedestrian and Vehicular Circulation Objective C-1; and Athletic and Open Space Objective AOS-1. For these reasons, the avoidance of significant and unavoidable construction-related Air Quality and Noise impacts, which would entail the elimination of new construction throughout most of the LMU campus, was rejected as a feasible alternative for detailed evaluation and comparison to the Proposed Project. City of Los Angeles VI-14 Loyola Marymount University Master Plan Project Draft EIR

15 3.3.3 Alternative to Eliminate Significant Cumulative Solid Waste Impacts Proposed Project operation was determined to result in a cumulatively considerable contribution to cumulatively significant and unavoidable Solid Waste impacts, potentially exceeding the capacity of landfills serving Los Angeles County during the 20-year timeframe of Proposed Project buildout. Increased waste generation associated with Proposed Project operation would stem from the Proposed Project s net increase in the number of beds on campus and from the net increase in nonresidential square footage (i.e., academic, administrative, and indoor athletic facilities). Specifically, the Proposed Project would house 75 percent of the undergraduate population on campus, compared to 60 percent as of Fall Since Fall 2008 enrollment was 5,441.8 FTE undergraduate students and the Proposed Project seeks to increase undergraduate enrollment to 5,500 FTE undergraduate students as part of an overall enrollment cap of 7,800 FTE students, this would increase the number of beds on campus from 3,261 to 4,250, or 989 new beds (including beds for faculty and staff living in student residential buildings). In order to avoid increasing solid waste generation over existing conditions (i.e., Fall 2008 levels), under this alternative it is assumed that LMU would limit its overall enrollment to 5,500 FTE students, including 4,000 FTE undergraduate students and 1,500 FTE graduate students, and would house 75 percent of that reduced number of FTE undergraduate students on campus. Housing for 75 percent of 4,000 FTE undergraduate students would not require the addition of net new beds (that is, the number of beds on campus would remain at no more than 3,261) or the construction of net new residential square footage over existing conditions, although existing residential square footage could be replaced with facilities of comparable sizes. The number of FTE staff and faculty would be capped at 1,200. The Proposed Project would enable LMU to construct approximately 508,000 net new square feet of academic and administrative facilities and approximately 28,000 net new square feet of indoor athletic facilities. In contrast, under this alternative, the number of net new square feet could not be increased over existing conditions and LMU would be permitted only to replace existing academic, administrative, and indoor athletic facilities with facilities of comparable sizes. Although this alternative would permit construction of less new square footage and housing of fewer FTE undergraduate students than under the Proposed Project, other components of the Proposed Project could still be implemented under this alternative, including but not limited to, improvements to outdoor athletic facilities, construction of new outdoor athletic facilities, the construction of new parking structures, and the replacement of existing, obsolete buildings with new buildings totaling an equivalent square footage. City of Los Angeles VI-15 Loyola Marymount University Master Plan Project Draft EIR

16 Since this alternative would permit less new construction than the Proposed Project, it would result in reduced construction air quality impacts pertaining to localized significance thresholds compared to the Proposed Project. However, impacts from construction air quality would remain potentially significant and unavoidable, since even a reduced amount of construction is likely to result in exceedance of localized significance thresholds at the same sensitive residential receptors and planned LAUSD school that would be affected by the Proposed Project, because of their proximity to parts of campus that could be redeveloped under this alternative. Noise impacts are also likely to remain significant and unavoidable under this alternative, since, under the Proposed Project, such impacts stem from the potential proximity of construction activities to off-campus residences streets surrounding the campus. Elimination of the Proposed Project s net new square footage would still allow construction of new buildings or other facilities that replace old facilities, or improvements to outdoor athletic facilities, anywhere on campus. This alternative is likely to result in other impacts similar to, or greater than, those identified as significant, though mitigable, under the Proposed Project. These include Light and Glare (since nighttime lighting of existing and new athletic facilities could still take place on Burns and Leavey Campuses); Climate Change (since trip generation, and therefore Vehicle Miles Traveled and associated emissions would not be reduced through housing an increased percentage of students on campus, and at least some older buildings are likely not to be replaced with more energy-efficient facilities); Biological Resources (since any new construction could still affect nesting birds, monarch butterflies, and protected trees on campus); Paleontological and Archaeological Resources (since construction could still occur in areas of campus with potential for the presence of such resources); Historic Resources (since construction under this alternative could still cause vibration damaging to existing historically significant buildings on campus); Geology (since new buildings and facilities would be subject to the same geological hazards as under the Proposed Project); Hazards (since the demolition of old buildings could still release asbestos, lead-based paint, and PCBs into the atmosphere, and new buildings and paved areas would still be sited within the Methane and Methane Buffer Zones); Traffic (since eliminating the ability to house up to 75 percent of FTE undergraduate students on campus is likely to result in greater trip generation, and therefore potentially significant Traffic impacts during peak hours); and Water Supply and Energy (since at least some older buildings are likely not to be replaced with newer energy-efficient and water-conserving facilities). Because this alternative assumes reduced student enrollment, a reduced number of FTE faculty and staff, no net new campus residential facilities or increase in the number of students housed on campus, and no net new non-residential square footage, it would severely constrain future growth of the campus. This would prevent attainment of Key University Objective U-3, ensuring the maximum number of students City of Los Angeles VI-16 Loyola Marymount University Master Plan Project Draft EIR

17 have opportunities to experience and contribute to LMU s social living and learning environment, student and faculty interaction, and full participation in campus life through increased and improved on-campus housing opportunities. It also would prevent attainment of the Key University Objectives: implementing LMU s three-old mission by creating an updated, cohesive campus community and environment with a critical mass of approximately 7,800 FTE students (Objective U-1), and attaining certainty regarding future development on campus that allows for future growth, the pursuit of LMU s mission, and promotion of its other Key University, Academic, Residential, and Sustainability Objectives (Objective U-2). The inability under this alternative to construct any net new academic, administrative, and athletic facilities would allow attainment of Key Academic Objective A-1, replacing academic, administrative, athletic, and residential spaces and buildings that are functionally obsolete to create a functionally cohesive environment on campus, but would allow only incomplete attainment of Key Academic Objective A-2, building sufficient state-of-the-art facilities to house future academic, research, and residential facilities on campus, to aid in the recruitment and retention of top students, the recruitment of faculty and conversion from part-time to full-time status, and the creation of the best possible academic community and student social living and learning environment. The inability under this alternative to construct net new student residential housing on campus, or to house more students than under existing conditions, would prevent attainment of three Key Residential Objectives: contributing to the alleviation of the regional housing shortage (Objective R-1); increasing the percentage of FTE students housed on campus from approximately 60 percent to approximately 75 percent (Objective R-2); and addressing community concerns regarding students living off-campus by moving more undergraduate residential students onto campus (Objective R-6). It would allow incomplete attainment of two Key Residential Objectives: enhancing campus student life by raising the standard of on-campus housing through increased unit size and improved amenities (Objective R-3); and fostering community and a communal educational environment by increasing the number of FTE undergraduate students living on-campus and by replacing outdated student housing units with updated social-living units (Objective R-4).Key Residential Objective R-5, replacing aging student residential rooms and apartments with modern residential accommodations, to improve the educational environment on campus, could be attained under this alternative, since it would not preclude replacement of existing housing with new housing of similar size. This alternative would allow incomplete attainment of Key Sustainability Objective S-1: creating a sustainable campus environment by incorporating green building and landscaping practices, reducing the production of greenhouse gas emissions and solid waste, and reducing consumption of water, electricity, natural gas, and energy. It would prevent the attainment of Sustainability Objective S-2: Move City of Los Angeles VI-17 Loyola Marymount University Master Plan Project Draft EIR